Dear Colleagues
This report addresses a number of important regulatory and operational matters currently affecting the real estate industry. While detailed, we encourage you to review the contents carefully, as many of these issues have direct implications for your business operations and regulatory compliance.
REBOSA is actively engaging with the PPRA and other relevant authorities, and where necessary, consulting with our legal advisors on several of the matters raised.
We also recently met with the PPRA Board to formally table key industry concerns and propose practical solutions, and we are hopeful that this engagement will yield constructive outcomes and further strengthen our working relationship with the newly appointed Board.
Further regulatory changes are anticipated, with new Regulations expected to be published which may have far-reaching implications for the industry. It is therefore important that members remain informed and aligned. REBOSA will continue to represent the collective interests of the industry, and we thank you for your ongoing support as we address these matters through a unified and coordinated approach.
Kind regards
Jan
PPRA Admin Fees
REBOSA has raised serious legal concerns regarding the legitimacy of the PPRA charging administrative fees for services that are already prescribed in terms of the Property Practitioners Act and its Regulations. We have formally engaged the PPRA Legal Division on this matter, as it is our view that the imposition of certain administrative fees may not be supported by the current legislative framework.
REBOSA is also consulting with its legal advisors on the lawfulness of these charges and to determine the appropriate course of action.
Members will recall that when administrative fees were introduced in November 2024, REBOSA formally challenged their implementation. Following these engagements, the PPRA withdrew the administrative fee requirement for FFC applications and renewals. While this represented a significant outcome for the industry, other administrative fees remained in place, despite our submissions at the time.
Were it not for securing the withdrawal of this admin fee, every practitioner would have paid an additional R640 for their FFC.
REBOSA will continue to pursue all appropriate engagements and, where necessary, legal remedies, with the objective of:
- Seeking withdrawal of administrative fees that are not legislatively supported; and
- Requesting refunds where such fees may have been incorrectly imposed on practitioners.
However, members should note that we cannot guarantee the outcome or timeframe of this process, as it will require ongoing regulatory engagement with the PPRA or formal legal proceedings.
In the interim, Members must pay the required fees to avoid operational disruption pending the outcome of these engagements.
PPRA Penalties and Fines – Regulation 38
REBOSA has raised ongoing concerns regarding the PPRA’s approach of imposing maximum fines for minor or first-time contraventions, without taking into account mitigating factors such as materiality, intent, or compliance history.
In engagements with the PPRA, it has been indicated that inspectors apply fines in line with Regulation 38 and do not exercise discretion, with practitioners required to approach adjudication to seek relief, which can be costly and impractical.
REBOSA is actively challenging this approach, as we believe penalties should be proportionate, fair and take into account minor transgressions and first-time offenders, and we are continuing our engagements to seek a more balanced and reasonable enforcement framework.
Penalties for Non-Submission of Audit Reports
REBOSA has noted instances where practitioners are being fined R25,000 for the alleged non-submission of audit reports, despite holding valid trust account exemption letters.
In these cases, practitioners are only required to obtain an independent review of their financial statements, which are not required to be submitted to the PPRA Audit Department unless specifically requested or during an inspection.
We have raised this matter with the PPRA, as these fines appear to be incorrectly imposed.
The current dispute process is lengthy and onerous, requiring practitioners to navigate multiple layers of review before the matter can be adjudicated and resolved.
REBOSA has therefore requested that a streamlined resolution mechanism be introduced for cases where practitioners clearly hold valid exemptions and should not have been fined. We are awaiting feedback from the PPRA.
Incorrect Dates of Issue on FFCs
It has come to our attention that where Principals, Firms or Practitioners were issued with FFCs after 1 January 2026 due to the PPRA backlog, the date reflected on the FFC corresponds to the system-generated issue date, rather than the intended validity date of 1 January 2026.
In a number of instances, this results in practitioners appearing not to have held a valid FFC for a period of days or weeks, despite having submitted compliant renewal applications within the prescribed timeframe. This creates a significant practical risk, particularly where conveyancers refuse to release commission for transactions concluded during this apparent gap period, on the basis that the FFC reflects that the Principal, Firm or Practitioner was not licensed at the time of the transaction.
REBOSA has raised this matter with the PPRA as a serious operational and legal concern. The PPRA has confirmed that the current system does not allow for backdating and re-issuing of FFCs once generated. As an interim measure, the PPRA has undertaken to issue confirmation letters for affected practitioners, confirming that:
- a compliant application was submitted timeously;
- the practitioner should have been issued with a valid FFC effective 1 January 2026; and
- the practitioner was therefore entitled to trade lawfully during the affected period.
These letters may be provided to conveyancers as supporting confirmation to facilitate the release of commission.
Members who require such confirmation may request REBOSA to facilitate this process with the PPRA on their behalf.
This concession applies only to practitioners who submitted compliant applications prior to the renewal deadline of 30 November 2025. Where applications were non-compliant, incomplete, or submitted late, any gap reflected in the FFC issue date will remain, and the PPRA has indicated that these dates will not be amended or corrected.
Deregistration of Agents with Valid FFCs
REBOSA is contesting the automatic deregistration of agents in circumstances where there is a short gap between employment changes, particularly where a Principal de-links an agent and the agent is in the process of submitting a new letter of employment, or where the practitioner is actively seeking new employment. In practice, these transitions may take several days or weeks, which has resulted in agents being deregistered and required to apply for a new FFC.
Our position is that the Property Practitioners Act only permits the withdrawal or lapse of a Fidelity Fund Certificate under specific circumstances (Section 52), and that a temporary change in employment does not automatically invalidate an existing FFC that remains valid for the relevant period. REBOSA therefore strongly opposes the requirement that practitioners in these circumstances must pay for the issue of a new FFC, where the original certificate has not lawfully lapsed or been withdrawn. We are currently seeking legal advice on this matter and will continue engaging with the PPRA to resolve this issue.
De-linking of Agents from Firm Profile
Members are reminded that when an agent leaves a firm, the PPRA must be notified in writing within 14 days in order to update the firm’s profile and de-link the practitioner.
This requirement is prescribed in Regulation 15.8 of the Property Practitioners Regulations, 2022, which provides as follows:
“The holder of a fidelity fund certificate or a registration certificate, as the case may be, shall inform the Authority within fourteen (14) days of any change in the information supplied to the Authority at the time of applying for the issue to him/her of such certificate”.
Failure to update practitioner information timeously may result in FFCs being issued under the incorrect firm, which places both the firm and the agent at regulatory risk, including, inadvertent deregistration of agents and compliance exposure for Principals.
During the recent renewal period, we encountered numerous instances where FFCs were issued under incorrect firms, primarily due to changes not being communicated to the PPRA within the prescribed timeframe.
We are also currently dealing with a number of queries where agents were inadvertently deregistered, either:
- Following notification by a firm that the agent had left, or
- Where an agent independently notified the PPRA of a change without alignment with the firm
Members are therefore encouraged to periodically review their firm profiles and verify:
- All agents are currently linked to the firm
- Resigned agents have been de-linked
- New agents are correctly linked
- Principal and firm details remain accurate
Outstanding Firm FFCs
We continue to receive a high volume of queries relating to Firm FFCs that have not been issued. In many cases, Principals have renewed their personal FFCs, but no Firm FFC has been applied for, as the previous automatic generation no longer applies.
Members are requested to check their MyPPRA portal and confirm that:
- each firm has a valid Firm FFC; and
- the Firm FFC corresponds with the correct Principal and entity
Where a Firm FFC has not been issued, a separate application must be submitted, together with payment of the PPRA administrative fee (currently R704.00).
REBOSA Firm FFC Application Process
To assist members, REBOSA has created a streamlined Firm FFC application form to facilitate submission to the PPRA.
Members may access the application here:
https://www.rebosa.co.za/firm-fidelity-fund-certificate-firm-ffc/
We encourage Principals to utilise this process to avoid further delays and ensure that Firm FFCs can be issued without further interruption.
New Candidates and 7 Digit Reference Numbers
Due to the PPRA system not operating as intended, new candidates are no longer able to obtain 7-digit reference numbers automatically from the system. All new candidates must first obtain this reference number before they can make payment and submit a full application for their Fidelity Fund Certificate (FFC). This has resulted in significant delays in candidate registrations.
The process now requires applicants to first submit an application form, copy of ID, and letter of employment (without a 7-digit reference number). Once the reference number has been issued, the applicant must then make payment and resubmit a revised letter of employment reflecting the allocated 7-digit reference number. The PPRA has up to 30 working days to issue the reference number, as this is treated as a new application, and a further period of up to 30 working days may be required for the FFC to be issued. Until the system is restored and 7-digit reference numbers can again be generated automatically, applicants are strongly encouraged to submit their requests as early as possible to mitigate delays.
PPRA Fee Increase 2026/2027
The PPRA has increased fees with effect from 1 April 2026.
Prescribed fees have increased by 3.5% (CPI-linked adjustment)
Non-prescribed fees, including certain administrative and PDE-related fees, have increased by up to 10%
Members are strongly advised to consult the updated Schedule of Fees before making any payments to the PPRA.
Payment of incorrect amounts will result in the need to make top-up payments and additional delays.
Please ensure that you only use your 7-digit reference number when making payment. Alphanumeric references are not recognised by the PPRA system and will result in your payment being placed in a suspense account until manual allocation is requested, which can cause further processing delays.
Please refer to the updated Schedule of Fees here:
https://www.rebosa.co.za/ppra-schedule-of-fees-1-april-2026-to-31-march-2027/
Where you have used an incorrect reference number on a payment you need to send a payment allocation letter to the PPRA finance department to have the funds allocated to your account. Rebosa can provide you with a fund allocation letter template if required.
Top-up Fees
The PPRA is currently applying top-up fees to applications across various departments where processing takes place after 1 April, even if the application was submitted prior to the fee increase.
However, the Registrations Department has confirmed that, in respect of FFC applications, no top-up fee is required where a compliant application and payment were submitted before 1 April 2026.
REBOSA will seek to secure the same concession across other departments, including Education, equivalency exemptions, trust account exemptions, and E1 exemptions, to ensure consistent and fair application of the revised fee structure.
Financial Intelligence Centre (FIC) Update
The Financial Intelligence Centre (FIC) recently issued a number of requests for public comment relating to proposed directives and guidance concerning Risk and Compliance Returns (RCRs) and Risk Management and Compliance Programmes (RMCPs).
Members are advised that communications received from the FIC during this period were calls for comment only. No action was required unless one wished to make submissions.
REBOSA has submitted formal commentary on all relevant requests. We understand that the FIC has taken these submissions into consideration as part of its consultative process.
REBOSA maintains an ongoing and constructive working relationship with the FIC, and we continue to engage proactively on regulatory developments affecting the sector. It remains in the interests of all members to support regulatory compliance and to align with FIC requirements as they are finalised.
Please note: The Risk and Compliance Return (RCR) should not be confused with the Risk Management and Compliance Programme (RMCP). These are two separate requirements.
The RMCP is your internal document that outlines your firm’s risk-based approach, policies, controls, and procedures in terms of FICA. This must be developed, implemented, and maintained by your firm.
We recently held a webinar on FIC compliance and have created a RMCP compliance folder with templates, guidelines and checklists along with a link to the webinar recording. Email info@rebosa.co.za for access to the folder.
Risk Compliance Return
The RCR is an annual return submitted to the FIC, where accountable institutions confirm and report on the implementation of their RMCP and overall compliance.
Estate agencies are required to submit their returns by 31 July 2026 before 17h00. The submission period opens on 4 May 2026, providing estate agencies with sufficient time to meet the deadline.
We strongly encourage you not to leave your submission until the last minute.
Fidelity Fund Certificate Update
The 2026 renewal cycle was significantly impacted by ongoing system failures at the PPRA, which resulted in thousands of Fidelity Fund Certificates being issued after 1 January 2026. This created operational and compliance challenges for firms and practitioners, particularly where commission payments depend on a valid FFC.
Members who submitted their renewal applications via the PropCert platform, and whose applications were compliant at the time of submission, have now all been issued. We are pleased to confirm that no outstanding compliant PropCert-facilitated queries remain.
There are, however, outstanding FFCs relating to applications submitted directly to the PPRA. We continue to work closely with the Authority to resolve these matters and facilitate the issuance of these FFCs.
We have also identified a number of delays arising from non-compliant submissions, including:
- submission of proof of payment only, without a completed renewal application
- incorrect or incomplete supporting documentation
- incorrect payment references (including missing 7-digit reference numbers)
- incomplete employment or firm details
Members are reminded that the PPRA has 30 business days to process and issue a FFC from receipt of a compliant application. Where the PPRA requests additional information or supporting documentation, the processing 30-day period effectively recommences from the date the additional information is received.
Accordingly, where applications are incomplete or incorrect, processing timelines can extend significantly, in some cases resulting in delays of up to 90 days. Members are therefore strongly advised to ensure that applications are complete and compliant at the time of submission, as incomplete submissions will materially delay the process.
Changes to FFC Issuing Structure
During the recent FFC renewal cycle, the PPRA introduced a number of operational changes to the issuing of Fidelity Fund Certificates, largely to address system limitations and configuration issues experienced on the PPRA platform.
Members are encouraged to refer to the PPRA stakeholder webinar and presentation for further detail.
The key changes are summarised below:
Separation of Principal, Firm and Agent FFCs
Historically, Principal, Firm and Employee FFCs were interdependent. When a Principal renewed their FFC under a specific firm, the Firm FFC was automatically generated, and agent FFCs would then issue based on that configuration. Where the Principal did not renew under a firm, the Firm FFC and agent FFCs would not be issued.
This position has now changed.
Firm FFCs are no longer automatically generated when a Principal renews.
Firm FFCs must now be applied for separately.
Agents FFCs remain dependent on both the Firm and Principal being compliant and holding valid FFCs
New “Floating” FFC Structure
The PPRA has also implemented a “floating FFC” structure:
Principals: One floating FFC which may be linked to multiple firms
Agents (Non-Principal/Candidates): May only be linked to one firm/employer at a time
Principals must therefore ensure that:
- their personal FFC is renewed when due, and
- each Firm FFC is applied for and renewed separately
These expiry dates may not coincide, and both must be valid for agents to be issued with FFCs under the firm.
Historical Penalties for Returning Practitioners
Members are reminded that, following formal engagement by REBOSA, the PPRA abolished the imposition of historical penalty fees on practitioners returning to the industry after a period of absence, with effect from 20 June 2024, provided that the practitioner did not operate as a property practitioner during the period of absence.
Despite this position, REBOSA continues to receive reports that historical penalties are still being levied in certain instances, particularly where practitioners or firms are unaware of the concession or do not submit the required supporting documentation.
Principals are therefore encouraged to carefully assess practitioners returning to the industry to determine whether they qualify for exemption from historical penalties. Where applicable, the firm should ensure that the required affidavit and supporting documentation confirming that the practitioner did not operate during the period of absence is submitted to the PPRA at the time of application.
PPRA IT System
REBOSA remains concerned about the ongoing instability and dysfunction of the PPRA system, which continues to affect virtually every area of the Authority’s operations.
The lack of a stable and reliable system has resulted in delays, inconsistencies, and administrative challenges for agents and firms across the industry.
We were advised that a new system was scheduled to be launched on 1 April 2026; however, no further communication or implementation details have been provided, and it appears that the rollout has been delayed.
REBOSA will continue to engage with the PPRA on this matter, as a functional and reliable system is critical to the effective regulation of the industry and the day-to-day operations of property practitioners.
Property Practitioner “Search” Feature on PPRA Website
REBOSA has raised serious concerns regarding the Practitioner Search functionality on the PPRA website, which is currently not properly populated or updated. As a result, registered practitioners are in some instances reflected as “invalid”, “expired” or “not found”, despite holding valid Fidelity Fund Certificates. This materially affects our members, particularly where sellers, buyers and other stakeholders rely on the PPRA website to verify an agent’s credentials, which may lead to reputational harm and loss of business for compliant practitioners.
REBOSA formally requested that the PPRA remove or disable this feature with immediate effect until the data integrity issues are resolved. In its response, the PPRA acknowledged our concerns and recognised that inaccurate search results affecting valid FFC holders are unacceptable and inconsistent with its service standards. The PPRA has requested a meeting to further discuss our concerns, including considerations relating to POPIA and other legislative requirements cited as reasons for keeping the functionality live. Although the last two scheduled meetings were cancelled, REBOSA will continue to pursue this matter as a priority to ensure that members are not prejudiced by inaccurate information published on the PPRA website.
Information Regulator and PAIA Annual Returns
In accordance with section 83(4) of PAIA, Private Bodies have to submit to the Regulator, their Annual Reports about requests for access to records received and processed by the private body. The Information Regulator has developed an online submission platform for Annual Reports in terms of sections 32 and 83(4) of PAIA. This functionality is available under the eServices portal, which can be accessed via the Regulator’s website at https://inforegulator.org.za, or by going directly to the Regulator eServices portal, accessible on https://eservices.inforegulator.org.za.
The submission period will open on 01 April 2026 and close on 30 June 2026. Kindly note that no extensions will be granted beyond the closing date.
All responsible parties are strongly encouraged to submit their Annual Reports as early as possible and not to wait until closer to the deadline. Early submission will assist in avoiding system congestion and ensure compliance within the prescribed timeframe.
Professional Development Exam (PDE) – 12 February 2026
REBOSA lodged a formal complaint with the PPRA regarding the administrative and system failures affecting the PDE examination of 12 February 2026, including portal instability, registration issues, late payment and seat allocations, the uploading of an incorrect PDE5 paper, and material errors in the examination papers. The PPRA acknowledged the complaint and issued an erratum; however, it remains unfortunate that candidates who wrote PDE5 and were provided with an incorrect or defective examination will be required to rewrite, through no fault of their own. REBOSA has emphasised that such failures materially impact candidates’ professional progression and has called for immediate corrective measures to prevent a recurrence.
https://www.rebosa.co.za/erratum-12-february-2026-professional-designation-exam-pde-5/
https://www.rebosa.co.za/examination-notice-practitioners-who-wrote-pde-4-instead-of-pde-5/
Professional Development Exam (PDE) – 14 May 2026
The registration period for the PDE examination scheduled for 14 May 2026 is open. Candidates must register and pay for the PDE before 30 April 2026.
Candidates must log in to the Property Practitioners portal to register.
EISA Exam
The first sitting of the EISA, was marked by significant administrative and examination concerns. The EISA is the final integrated summative assessment that candidates must successfully complete after obtaining the NQF4 qualification, before they are permitted to write the Professional Designation Examination (PDE).
The level of dissatisfaction reported raises serious concerns about the readiness, fairness and consistency of the examination, particularly where the assessment does not appear to adequately test real-world competency.
REBOSA is currently conducting an in-depth investigation into these issues and is engaging with the relevant authorities at the highest level to ensure that future assessments are professionally administered, practically relevant, and aligned to the competency requirements of property practitioners operating in the real estate environment.
REBOSA Calls for Reform of Education and Training Standards
REBOSA is calling for a comprehensive overhaul of the current education and training framework for candidate property practitioners. In its current form, the framework is costly, administratively burdensome, and does not adequately equip candidates with the practical competencies required in the real estate environment.
It also does not support meaningful transformation objectives or align with the intent of the Property Practitioners Act, which contemplates that candidates should be able to complete the qualification pathway within 180 days, with a further 180-day extension where necessary.
The misalignment between the legislative intent and the current framework is further evidenced by the PPRA having to grant candidates a 27-month extension to complete qualification requirements.
REBOSA has submitted proposals and is currently engaging with the relevant authorities to review and reform the existing standards to ensure a more practical, accessible and legislatively aligned pathway to qualification.
Continuing Professional Development (CPD)
Members are reminded of the importance of completing their annual CPD requirements to remain compliant with PPRA obligations.
Charter Academy is hosting a CPD webinar on 14 April, where property practitioners can complete all four required CPD modules in a single sitting. The one-morning session is offered at an all-inclusive cost of R1,480, with certificates issued after the webinar to enable practitioners to secure their CPD points. The programme is PPRA approved.
Click here for more information.
Homeowners Associations (HOAs)
Following the PPRA’s temporary suspension of enforcement action pending the court proceedings between PPRA and ARC/RCC, the industry remains in a difficult position. The PPRA is not pursuing enforcement action against practitioners until the court matter, currently scheduled for hearing on 4 May 2026, has been finalised. REBOSA continues to receive complaints that certain HOAs are still insisting on the payment of accreditation or participation fees and are not holding such amounts in trust pending the outcome of the court case, as contemplated. The PPRA does not have jurisdiction over HOAs in this regard.
This has placed practitioners in an untenable position, effectively requiring them to decide whether to pay the fees in order to continue trading or risk exclusion, notwithstanding that the regulatory position remains unresolved. Unfortunately, there is limited recourse available at this stage pending the outcome of the court proceedings.
The full notice can be accessed on the link below: –
